ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

molestation from discovery. It is for this reason, among others, that production of the tape on which he speaks about his molestation is critical. A. Epstein's Vicious Attacks on the Girls 5. Epstein's battery of attorneys have taken the girls' depositions, in which they have asked numerous questions sugg

tioned. Did some of those trips include travel to New York? A. Yes. Q. Where did you stay when you traveled with Maxwell and Epstein to New York? A. Epstein's house. Q. Where was that house located? A. New York City. Q. In what borough? A. Do you need the exact address? Q. No, it's okay. Approximately